7 minutes to read With insights from... Adam Goran Client Principal, Zühlke adam.goran@zuhlke.com Li Gardner Principal Business Consultant li.gardner@zuhlke.com Consumer Duty, introduced by the Financial Conduct Authority (FCA) in the UK in 2022, officially came into force in July 2023. It is a significant regulatory framework that sets higher and more precise consumer protection standards across the financial services industry. Its primary objective is to ensure that consumers receive the support they need, clear and understandable communications, and access to products and services that meet their needs and offer fair value. This initiative is critical in building trust and confidence in the financial services sector, which has seen declining consumer confidence and increasing complaints about service quality. Four key Consumer Duty outcomes: The FCA anticipates that the Consumer Duty will enhance results for consumers across all business interactions between companies and their customers. The Duty’s four outcomes address the fundamental aspects of the firm-consumer relationship. The four key outcomes include: Product and service design: Products and services should meet the needs of the target consumer group, considering suitability and intended benefits for different customer segments. Price and value: Pricing models must represent fair value, assessing whether the benefits justify the cost to the consumer. Consumer understanding: Financial services must ensure that customers understand the products and services they are using, providing clear, transparent, and accessible information for informed decision-making. Customer support: Adequate support must be provided throughout the customer journey, including effective after-sales service and timely issue resolution. In our opinion, there are two more key outcomes of Consumer Duty: Preventing harm: A proactive approach to identifying and mitigating potential consumer risks and harms involving ongoing monitoring and preventative measures. Monitoring and accountability: Regularly monitoring compliance with Consumer Duty, accountability for actions, and the mechanisms to review and report on performance and customer outcomes. These topics collectively ensure that financial services organisations prioritise customers' interests, enhancing trust and confidence in the industry. Value of a holistic service design approach Service design is particularly well-suited to effectively planning and implementing Consumer Duty due to its customer-centricity and holistic lens. Holistic service design involves comprehensive planning and execution of a product or service, from initial concept to final delivery and beyond, considering every touchpoint and interaction an employee and/or customer has with it, front or back of house. This approach ensures that all aspects of the service are mapped out for visibility and seamlessly integrated to focus on delivering value. Key elements include: A customer-centric approach: Puts the customer at the heart of the design process, understanding their needs, behaviours, jobs to be done and pain points. Cross-functional collaboration: Involves stakeholders from various departments to ensure a cohesive and unified service across the organisation. Continuous improvement: Regularly evaluates and refines the product or service based on feedback and performance metrics. Lifecycle management: Considers the entire customer journey, from acquisition to retention, ensuring consistency and quality throughout. Comprehensible ecosystem view: Visualises the collaboration model among various financial institutions to enable the delivery of a unified and seamless customer experience. See our guide to the modern financial services ecosystem Strategic guidance for implementing Consumer Duty through holistic service design As previously mentioned, service design can be invaluable in implementing Consumer Duty. So, how exactly can you approach Consumer Duty implementation through the lens of holistic service design? We have four key recommendations: Be holistic and adopt an outside-in perspective Be holistic and adopt an outside-in perspective Holistic service design creates an outside-in view of service performance in the real world by understanding value creation through all touchpoints, including frontstage and backstage processes. This requires a deep comprehension of human behaviours, organisational dynamics, and complex systems. Financial institutions must recognise that this outside-in view often differs from an inside-out view based on internal expertise, revealing customer pain points, unmet needs, service inefficiencies, and regulatory vulnerabilities. Be data-driven and establish evidence-based decision-making Be data-driven and establish evidence-based decision-making Financial service organisations should use qualitative and quantitative insights. Data visualisation tools like personas, journey maps, ecosystem maps, and risk heatmaps can bring understanding to life and inform evidence-based decision-making. Be lean and invest in continuous research and design Be lean and invest in continuous research and design Avoid siloed research; leverage actionable data insights to develop testable solutions through cross-functional co-creation of future state services. Financial institutions should adopt an agile design approach, emphasising rapid ideation, prototyping, and testing to gather timely feedback. This allows for early identification and resolution of compliance issues, enabling proactive adjustments and reducing non-compliance risk throughout the service lifecycle. Be cross-functional and provide teams with a practical service design framework and toolkit Be cross-functional and provide teams with a practical service design framework and toolkit Promote a collaborative, cross-functional approach to break down silos and foster departmental cooperation. Financial institutions should empower teams with a holistic service mindset and practical tools for service co-creation. For example, co-creating a service blueprint facilitated by service design experts can align teams on customer experience and operational processes, enhancing transparency and accountability in implementing Customer Duty requirements across all touchpoints in the service journey. Leveraging service design and consumer duty to develop an enhanced customer experience Customer centricity is the core of Consumer Duty and Service Design, crucial for rebuilding customer trust and confidence. Leveraging these principles allows financial services to turn regulatory requirements into opportunities for creating better customer experience. Consumer Duty necessitates operational changes, offering a chance to redesign services with a customer-first approach. Investments in training, system upgrades, and seamless service processes ensure staff can deliver exceptional experiences while complying with new regulations. Enhanced data capabilities are vital for monitoring customer outcomes and identifying improvement areas. Financial services should safely and securely utilise customer data to continuously refine services and establish accountability frameworks to uphold customer-centric values. Consumer Duty compels financial services to design products and services that meet consumer needs and ensure accessibility for all consumers, including those who rely heavily on cash and face-to-face services. The Financial Lives 2022 Survey report noted that 6% of adults in the UK still rely on cash and in-person services. Financial services must take an inclusive design approach to meet these consumers’ needs in the shift towards digital banking. While the survey found that 88% of UK adults use online or mobile banking, Consumer Duty ensures that digital services are user-friendly and accessible. This includes providing clear information and support for digital channels, reducing the digital divide, and ensuring all consumers benefit from technological advancements in financial services. Financial services organisations can transform compliance challenges into opportunities for enhanced customer experience, fostering trust and loyalty by focusing on these enhancements. For example, Zühlke helped HSBC UK successfully adapt its personal investment service to the UK market. By harnessing the power of customer research, the team identified a significant mismatch between the service’s initial configuration for the Asian market and the distinct needs of UK consumers. This insight led to a concerted effort to design the app service to better educate and guide customers to build their confidence and investment skills. As a result of the customer-centric approach, HSBC UK has seen year-on-year growth, with new investment business volumes increasing by 93%. Plus, the mobile journey has now become the preferred channel, with over 64% of customers opting to invest with HSBC UK through it. Read the full details of the HSBC story Continuous improvement and compliance for sustainable financial services Consumer Duty is not a one-time compliance exercise but a continuous commitment to improving customer outcomes. Financial services organisations are required to collect and act on customer feedback regularly. This feedback loop helps financial services promptly identify and resolve issues, consistently meeting their customers’ evolving needs. The regulation has a market-wide impact, with a significant percentage of financial services organisations adjusting their practices in response to Consumer Duty. This industry-wide shift towards higher consumer protection and service quality standards is expected to enhance the financial services sector's overall reputation, leading to increased consumer trust and confidence. Financial services organisations must leverage a product mindset with holistic service design by putting customers' lifelong financial health and wellbeing at the centre of their services. To achieve this, we suggest following our sustainable financial service model: Desirability: Meet the needs of targeted customers by being easy to understand and use, helping them achieve positive financial outcomes. Viability: Create sustainable commercial value for the business growth. Feasibility: It can be developed and implemented efficiently using existing technology and resources. Sustainability: Provide long-term benefits to customers and society, promoting enduring positive impacts. By focusing on these principles, financial services organisations can create products and services that support customers' immediate needs and contribute to their overall economic and societal wellbeing in the long run. Discover our approach to sustainable product development Creating customer-centric and Customer Duty-compliant financial services products and services The introduction of Consumer Duty represents a pivotal moment for the UK financial services sector, setting higher standards for consumer protection and customer experience. Financial services organisations can build customer trust and confidence by prioritising clear communication, tailored products, robust customer support, and fair pricing. Embracing holistic service design is vital. It ensures that every aspect of the customer journey is considered, fostering seamless interactions and positive outcomes aligned to employee touchpoints. Although compliance involves operational adjustments and costs, the long-term benefits include enhanced customer satisfaction, loyalty, and market reputation. Ultimately, Consumer Duty offers a significant opportunity for financial services to elevate their service standards and deliver exceptional value to their customers. Speak to our service design experts today
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